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- Title
International Tax Issues Corner: Interim Guidance on Foreign Withholding Obligations.
- Authors
Forst, David
- Abstract
The article focuses on the interim guidance on foreign withholding obligations as a result of Code Sec. 864(c)(8), based on Notice 2018-29, in the U.S. It offers explanation of the Tax Cuts and Job Act (TCJA) provision that overruled the result in the Grecian Mining, Industrial & Shipping Co. court case decision, that held that the sale by a foreign person of an interest in a partnership engaged in a U.S. trade or business was not subject to U.S. tax.
- Subjects
UNITED States; INTERNAL revenue law; TAXATION; FOREIGN corporation laws; TAXATION of business partnerships
- Publication
Journal of Passthrough Entities, 2018, Vol 21, Issue 5, p13
- ISSN
1099-7407
- Publication type
Article